Legal Opinion
First Chicago Corporation v. Commissioner of Internal Revenue
Court of Appeals for the First Circuit
Decided March 16, 1988No. 87-2028PublishedCited by 62 opinions
1Opinion of the Court
POSNER, Circuit Judge.
The government appeals from a decision by the Tax Court, 88 T.C. 663, holding that there is no minimum tax on tax-preference items until the items confer an actual benefit on the taxpayer. The facts are simple, their legal significance elusive.
In 1980 and 1981, First Chicago Corporation, the parent of the First National Bank of Chicago, had taxable income of $21 million and $39 million (we are rounding to the nearest million), on which income tax of $6 and $12 million would have been due had not First Chicago accumulated immense foreign tax credits. After applying these…
2Cases cited4 opinions
- Occidental Petroleum Corp. v. CommissionerUnited States Tax Court · 1984
- First Chicago Corp. v. CommissionerUnited States Tax Court · 1987
- Martin H. Fishman v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
- Aaron L. Kolom and Serita Kolom v. United StatesCourt of Appeals for the Ninth Circuit · 1986
3Cited by62 opinions
- Daniel Lee Vanskike v. Howard A. Peters, IIICourt of Appeals for the Seventh Circuit · 1992
- Allen v. Comm'rUnited States Tax Court · 2002
- Estate of Wallace v. CommissionerUnited States Tax Court · 1990
- Eldon R. Kenseth and Susan M. Kenseth v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 2001
- Bank One Corp. v. Comm'rUnited States Tax Court · 2003
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